The EPA’s Risk Management Plan (RMP) regulation (40 CFR Part 68) was issued in multiple stages, beginning in 1994. The regulation was modeled after OSHA’s Process Safety Management (PSM) standard (29 CFR 1910.119). The RMP regulation is about reducing chemical risk at the local level. The information from the RMP aids local fire, police, and emergency response personnel in responding to chemical accidents. It also helps citizens to understand the chemical hazards in their communities. The regulation has been left relatively unchanged since its issuance.

Under the regulation, companies of all sizes that use listed regulated flammable and toxic substances above threshold quantities are required to develop a Risk Management Plan and submit the plan to the EPA every 5 years. The RMP must include: Continue reading “Modernizing the Risk Management Plan (RMP) Regulation”

The purpose of this article is to walk you through the Boiler MACT applicability, compliance dates and what regulations are applicable to your facility’s boiler and/or process heater. The full names of Boiler MACT and GACT as published in the Federal Register 40 CFR Part 63, is as follows: Boiler GACT (Generally Achievable Control Technologies), in short refers to the USEPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) for Area Source: Industrial, Commercial and Institutional Boilers. Boiler MACT (Maximum Achievable Control Technology) refers to the USEPA’s NESHAP for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters.

The Four Rules

To figure what rule applies to your facility, you first need to understand the Boiler MACT basic 4 rules. Boiler MACT is used in a generalized form to include the following specific rules: Continue reading “Meeting Compliance Schedule and Requirements of Boiler MACT”

Does your facility have an air quality permit? If so, when was the last time it was updated? If your facility is not a major source of emissions, you may have an air permit with no expiration date. This can lead to situations where the air permit is 10 years, 15 years, or even older. Have facility operations not changed at all during that time? Has new equipment been installed? Are you sure that new boiler/oven/paint booth/etc. that was installed was truly exempt from an air quality permit? When was the last time the EPA or your State’s environmental agency inspected your facility? If you are a major source of emissions, you probably see your inspector annually, but if you are not a major emitter, the inspections can be much more random. Continue reading “STAYING IN COMPLIANCE WITH AIR QUALITY REGULATIONS”

Sources are required to submit a Notification of Compliance Status regarding the initial tune-up by July 19, 2012. 

On March 13, 2012, the EPA issued a No Action Assurance (NAA), stating that it would not enforce the Notification. The NAA states that it remains in effect until either (1) October 1, 2012, or (2) A final rule addressing the proposed reconsideration of the Area Source Boiler Rule, whichever occurs earlier.

On July 18, 2012, EPA extended the NAA for Boiler Area Source to December 31, 2012, or until the final rule is issued whichever occurs earlier.

For more information visit www.boilermactcompliance.com.

 

On March 13, 2012, the US Environmental Protection Agency, Office of Enforcement and Compliance Assurance, provided notice to associations and group representatives of owners of existing Area Source (GACT) boilers that the agency will exercise its discretion not to pursue enforcement for violations of the deadline to complete initial tune-up required in the final rule by March 12, 2012. In addition, the US EPA recently published a proposed re-consideration of the Area Source Boiler Rule that would postpone the tune-up from March 12, 2012 to March 12, 2013. This "No Action Assurance" applies to only the timelines of tune-up and the US EPA notes that nothing in this "No Action Assurance" affects any other provisions in the Area Source Boiler Rule. The "No Action Assurance" is to remain in effect until either (1) 11:59PM EDT October 1, 2012, or (2) the effective date of a final rule addressing the proposal reconsideration of the Area Source Boiler Rule, whichever occurs earlier.

The first compliance deadline for the Boiler GACT Rule is September 17, 2011 – when the Initial Notification of Applicability is due.  This rule applies to facilities with boilers fueled by any fuel except natural gas, and who are not major sources of Hazardous Air Pollutants (HAPs).  Some state agencies have already acted, with North Carolina DENR having recently mailed out letters to potentially affected facilities. Others, such as the Georgia EPD, will be sending out similar letters soon.  Whether or not you receive a letter, you will have to submit your initial notification by Sept. 17 if this rule applies to your facility.

The Boiler MACT rule, which applies to facilities that are major sources of HAPs, has been placed on legal hold. This means the large facilities have some breathing room, but the small facilities covered by the GACT rule must act now. 

More information is available at CTI’s Boiler MACT and GACT website – www.boilermactcompliance.com.

 

On May 16, 2011, the US EPA signed a stay delaying the effective dates for the final Boiler MACT rules for major sources for hazardous air pollutants (HAPs) and Commercial and Indstrial Solid Waste Incineration (CISWI) Units.

For Boiler MACT sources the deadline for compliance has not changed and is still March 21, 2012. This includes Minor Sources of HAP pollutants and Major Sources of non-HAP pollutants. 

The effective dates for HAP Major Source Boiler MACT & CISWI rules are delayed until such time as judicial review is no longer pending or until the US EPA completes its reconsideration of the rules, whichever is earlier.

For more information you can go to www.boilermactcompliance.com or contact us @ 770-263-6330.